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Consequences of impermissible avoidance arrangement.

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....t under a tax treaty, shall be determined, in the manner as deemed appropriate in the circumstances of the case. (2) The consequences of an arrangement declared to be an impermissible avoidance arrangement as referred to in sub-section (1) shall include but shall not be limited to the following:- (a) disregarding, combining or recharacterising any step in, or a part or whole of, the impermissib....

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Consequences of impermissible avoidance arrangement.